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Safeguarding Policy

1) Overview

At Caribou Digital (UK) Limited and its subsidiaries and affiliates (together, “Caribou”), everyone has the right to feel safe, irrespective of age, race, ethnicity, gender, gender identity, sexual orientation, disability, religion, political opinions, or culture. This Policy explains how we prevent, identify, respond to, and report harm connected to our work. It is published for client compliance and due-diligence purposes.

This Policy applies to Caribou personnel (employees, officers, board members, contractors) and to external parties who act for or with Caribou (consultants, agents/intermediaries, suppliers, vendors, partners, grantees, and research collaborators)—collectively, “Associated Persons.” Where local law differs, the higher/stricter standard applies.

2) What is safeguarding?

Safeguarding means keeping people safe from harm and exploitation. It includes protection of children (under 18) and adults at risk (whose circumstances—e.g., disability, ill-health, age, socio-economic factors, isolation, or power imbalances—may increase vulnerability). Vulnerability can fluctuate and may not be obvious; our safeguards therefore apply consistently.

What is “harm”? (non-exhaustive)

  • Sexual harassment, abuse, or exploitation; abuse of a position of trust
  • Bullying or harassment; threatening or intimidating behaviour
  • Discrimination or harassment on protected grounds (e.g., under the Equality Act 2010)
  • Physical, emotional or psychological abuse; domestic abuse; self-neglect
  • Health and safety failures; unsafe environments or practices
  • Data-protection breaches (e.g., mishandling personal data under UK GDPR)
  • Extremism/radicalisation; forced marriage; modern slavery and human trafficking

3) Principles we follow

  • Do no harm and act in the best interests of those affected
  • Respect, dignity, and inclusion; zero tolerance for discrimination and harassment
  • Proportionality: safeguards match the activity and risk
  • Accountability & transparency: prompt reporting and fair handling
  • Confidentiality: share information strictly on a need-to-know basis
  • Lawfulness: comply with applicable law and contractual requirements

4) Roles & responsibilities

Designated Safeguarding Lead (DSL): Chief Financial Officer (CFO)

  • First point of contact for safeguarding concerns.
  • Receives and triages reports; puts in place interim safety measures.
  • Coordinates proportionate investigations; keeps secure case records.
  • Liaises with authorities where required by law; maintains aggregated metrics.
  • Delivers/coordinates safeguarding briefings and awareness.

Deputy DSL: Chief Impact Officer (CIO)

  • Provides cover for the DSL and supports case handling.
  • Acts when the DSL is unavailable or conflicted (e.g., cases touching finance, vendors paid by Finance, or allegations involving the CFO).
  • Leads on digital/online safeguarding considerations (tools, remote sessions, data handling) and supports evidence preservation.

Senior Responsible Person (SRP): Chief Executive Officer (CEO)

  • Executive sponsor for safeguarding; ensures adequate resources.
  • Approves serious-incident decisions and external notifications recommended by the DSL/Deputy DSL.
  • Receives periodic aggregate reports; escalates to ELT/Board as appropriate.
  • Ensures lessons learned and improvements are implemented.

Managers & Project Leads

  • Plan activities with safeguarding in mind; brief teams and suppliers/grantees.
  • Ensure consent, safer environments (online/offline), and appropriate data handling.
  • Escalate concerns immediately to the DSL/Deputy DSL.

All Associated Persons (staff, contractors, suppliers, partners, grantees)

  • Comply with this Policy and report concerns promptly to the DSL/Deputy DSL or via cariboudigital.ethicspoint.com (see Whistleblowing (Speak Up) Policy).

Conflicts & escalation

  • If a concern involves the CFO/DSL, report to the CIO (Deputy DSL) or CEO (SRP), or use EthicsPoint Whistleblowing service.
  • If a concern involves the CIO/Deputy DSL, report to the CFO (DSL) or CEO (SRP), or use EthicsPoint Whistleblowing service.
  • If a concern involves the CEO/SRP or another ELT member, report to the DSL or Deputy DSL, or use EthicsPoint Whistleblowing service (for routing to the Board/Company Secretary).
  • Caribou may appoint an independent external investigator for serious/sensitive cases.

Availability & training

  • At least one of DSL/Deputy DSL will be available during business hours; contact details are kept current.
  • DSL and Deputy DSL will complete role-appropriate safeguarding training and refresh at planned intervals.

5) Safeguarding conduct standards (specific to safeguarding)

Research, fieldwork, partner visits & events

  • Behave responsibly; avoid conduct that could harm others or create unsafe spaces.
  • Follow any partner safeguarding guidance in addition to this Policy.
  • Consent for photography, video, interviews: obtain informed consent from the person or their responsible adult (and the child where appropriate); explain purpose, storage, sharing, and withdrawal rights; keep records.
  • Avoid creating or reinforcing harmful power dynamics (e.g., coercive incentives).
  • Gifts/hospitality can be a grooming risk—follow the Anti-Bribery & Anti-Corruption Policy (no cash/cash equivalents; proportionate; approvals where required).

Interactions with children & young people (rare but critical)

  • Treat children with respect; avoid words/actions that shame or humiliate.
  • Do not initiate physical contact; avoid being alone with a child.
  • No photos/videos unless necessary for work, with appropriate consent, and never without another adult present.
  • If you expect contact with children, notify the Safeguarding Lead in advance so proportionate measures can be arranged (e.g., supervision, vetting where lawful).

Online & remote engagement

  • Use respectful, inclusive language; moderate sessions to prevent harassment.
  • Protect privacy: minimise personal data, use secure tools, and follow the Privacy Policy.

6) Reporting concerns & responding to disclosures

If someone tells you about harm or a risk of harm:

Do

  • Ensure immediate safety (call local emergency services if needed).
  • Listen without judgment; keep calm; seek only factual clarification (do not investigate).
  • Explain next steps and that you cannot promise confidentiality.
  • Record what you were told (time/date, facts, who was present).

Don’t

  • Probe for detail or test credibility; confront alleged perpetrators; or share beyond need-to-know.

Report promptly via one of these routes:

What Caribou will do:

  • Acknowledge receipt (aim: within 7 calendar days).
  • Assess and triage risk; take interim safety measures as needed.
  • Investigate proportionately (may involve Legal/HR or external specialists).
  • Report to authorities where required by law or to protect people.
  • Protect reporters and participants from retaliation.
  • Record and learn: keep secure records; review controls after incidents.

Personal data in safeguarding reports is handled under our Privacy Policy and retained only as long as lawful and necessary.

8) Working with grantees, suppliers & partners

  • Risk-based due diligence: consider context/country risk, governance and safeguarding maturity, complaints mechanisms, and integrity risks. A site or virtual visit may be required for higher-risk engagements.
  • Safeguarding readiness: where a grantee lacks an adequate safeguarding policy, agree interim measures and a timeline to implement improvements (e.g., before the next disbursement).
  • Data handling: support partners to handle personal and sensitive data appropriately; share only what is necessary and lawful.
  • Active management: grantees/partners must notify Caribou promptly of safeguarding incidents linked to Caribou-funded activities, provide a brief summary and actions taken (without identifying survivors), and follow their own procedures including any legal notifications to authorities.
  • Records: maintain private engagement files and risk notes for audit purposes.
  1. Training, awareness & safer engagement
  • Induction training for new staff/contractors; periodic refreshers based on role and risk.
  • Activity-specific briefings before fieldwork, events, or research with participants.
  • Role-appropriate vetting/background checks where lawful and proportionate (e.g., work involving children or adults at risk).
  • Clear contact routes (Safeguarding Lead, Operations Director, Speak Up portal) are published and kept current.

Related Policies